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New Project and Expenditure Guidance released with reporting due April 30

On April 1, 2022, the U.S. Treasury released an update to its Project and Expenditure Report User Guide for the American Rescue Plan Act (ARPA) and State and Local Fiscal Recovery Funds (SLFRF). This version of the guide is applicable only to the Project and Expenditure Report (P&E) due by April 30, 2022. It is anticipated that the guide will be revised again for P&Es due in July 2022.

All recipients of SLFRF are required to submit a P&E by the end of April 2022. For some recipients, this will be the second quarterly report. For others, this will be their first annual P&E.

The prior version of the guide was published prior to the release of the ARPA Final Rule. Version two of the guide primarily details the changes which were made to the P&E Reporting Portal in order to implement the Final Rule, which became effective on April 1, 2022.

Summary of changes

The portal continues to be organized around “modules,” which are intended to be completed in sequential order. The seven modules used previously are retained, one new module has been added and one has been re-named. These modules are:

  • Introduction/Bulk Templates (NEW)
  • Recipient Profile
  • Project Overview
  • Subrecipients/Beneficiaries/Contractors (RENAMED to include “Contractors”)
  • Subawards/Direct Payments
  • Expenditures
  • Recipient Specific
  • Certification

Introduction/Bulk Templates

The new Introduction/Bulk Templates module includes helpful links. In addition to a link to the guide, users can download the bulk upload templates, either as a group or individually for projects, subrecipients, subawards or expenditures.

Recipient Profile

Within the Recipient Profile module, the only significant change is the addition of the SAM.gov Unique Entity Identifier number (UEI). As of April 2022, the Treasury is requiring all SLSRF recipients to have a SAM.gov registration. Once a SAM.gov registration has been established, the recipient’s UEI will be viewable on the SAM.gov website.

Project Overview

The Project Overview module is where most of the Portal changes occurred.

  • No projects to report – All recipients are asked to indicate whether “My jurisdiction has projects to report” or “My jurisdiction does NOT have projects to report.” Selecting the latter triggers a prompt to provide a narrative describing the reason(s) the recipient has no projects to report. After providing the narrative, the recipient can proceed to Certification, skipping the remaining modules.
  • Project descriptions – The guide clarifies that project descriptions should be 50-250 words in three to five sentences and include the project purpose, population served, desired outcome and how the outcome is being measured.
  • Additional information required for certain expenditure categories within public health and negative economic impact – This includes identification of populations impacted and/or disproportionally impacted as defined in the Final Rule (definitions provided in Appendix G to the guide). Also included is a description of the recipient’s objectives of the assistance program and their approach to ensuring the response is reasonable and proportional.
  • Capital projects “Written Justification” – For capital projects reported under certain Public Health and Negative Economic Impact expenditure categories and the Public Health-Negative Economic Impact: Public Sector Capacity category, recipients are asked to indicate the total cost of any capital expenditures, including pre-development costs. For enumerated uses of $10 million or more and capital expenditures for an "other" expenditure category of $1 million or more, recipients are required to provide a Written Justification (this field is optional in April 2022; required in July 2022). A Written Justification must include a description of the harm or need to be addressed, an independently prepared explanation of why a capital expenditure is appropriate and an objective comparison of the proposed capital expenditure against alternative capital expenditures.
  • Use of evidence – For relevant expenditure categories, states, U.S. territories, and metropolitan cities and counties with population over 250,000 must identify the dollar amount of the total project spending that is allocated towards evidence-based interventions and whether a program evaluation of the project being conducted has been completed.
  • Infrastructure eligibility – For water, wastewater and broadband projects, there are additional questions reflecting the expanded eligibility contained in the Final Rule.
  • Revenue loss – With the April 2022 P&E report, recipients will make a one-time, irrevocable selection as to how they wish to determine revenue loss. Recipients will respond “yes” or “no” to the question; “Is your jurisdiction electing to use the standard allowance of up to $10 million, not to exceed your total award, for identifying revenue loss?” If “yes,” recipients will be asked to indicate the amount of revenue loss to be claimed. For awards less than $10 million, the amount claimed cannot exceed the total allocation. For awards of $10 million or greater, the amount claimed may be up to $10 million. Those electing to calculate their revenue loss must make the calculation for both 2020 and 2021 (if information is available).

Subrecipients/Beneficiaries/Contractors

For subrecipients identified in the Subrecipients/Beneficiaries/Contractors module, use of a DUNS number is no longer permitted to identify a subrecipient entity. Instead, a SAM.gov Unique Entity Identifier (UEI) or Tax Identification Number (TIN) must be used.

Expenditures

Expenditure Category 6.2, Non-federal Match for Other Federal Programs has been added to categories not required in the Subawards/Direct Payments module.

Within the Expenditures module, expenditures to individuals – regardless of amount – are now reported in aggregate by project. Projects entered under expenditure categories 6.1, Provision of Government Services and 6.2, Non-federal Match for Other Federal Programs do not require entry of Subrecipient, Subaward or Expenditure (for a subaward) information for the April 2022 reporting cycle.

Recipient Specific

There were no changes to the Recipient Specific module, which continues to be applicable only to states and U.S. territories.

Certification

The Certification module adds a "Review" table which indicates whether the Project, Subaward and Expenditure modules are complete or incomplete and provides instruction on correcting errors.

Tom L. Kaleko
Principal
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